ECFVG Policies and Procedures - CPE Accommodations

December 2011
 

Introduction—In accordance with the Americans with Disabilities Act and other applicable laws, the AVMA/ Educational Commission for Foreign Veterinary Graduates (ECFVG) provides equal access to programs and services for individuals with documented disabilities.

The Americans with Disabilities Act of 1990 (ADA) and accompanying regulations define a person with a disability as someone with a physical or mental impairment that substantially limits one or more major life activities such as walking, seeing, hearing, or learning. The purpose of documentation is to validate that the applicant is covered under the ADA. Comprehensive information by a qualified professional is necessary to allow the ECFVG to understand the nature and extent of the applicant's disability and the resulting functional impairment that limits access to its examinations. Documentation also allows the ECFVG to provide appropriate accommodations for such a disability.

Documentation submitted by an applicant in support of a request is reviewed by the ECFVG for consideration and will be forwarded to outside experts for impartial professional review.

The ECFVG Policy on Testing Accommodations provides individuals, schools, professional diagnosticians, and service providers with information regarding how to document a disability and a related need for accommodations for candidates for the ECFVG Clinical Proficiency Examination (CPE). The information and documentation submitted should be as comprehensive as possible in order to allow the ECFVG to make an informed decision on the accommodation request and to avoid time delays in the decision-making process.

The purpose of accommodations is to provide equal access to the CPE. Accommodations "match up" with the identified functional limitation so that the area of impairment is mitigated by an auxiliary aid or adjustment to the testing procedure. Functional limitation refers to the behavioral manifestations of the disability that impede the individual's ability to function; that is, what someone cannot do on a regular and continuing basis as a result of the disability. For example, a functional limitation might be an inability to hear within normal limits. An appropriate accommodation might be use of an amplified stethoscope. It is essential that the documentation submitted with an accommodations request provide a clear explanation of the functional impairment and a rationale for the requested accommodation.

As noted in the CPE Manual of Administration, the Clinical Proficiency Examination (CPE) is a hands-on examination of entry-level educational clinical skills and judgments designed for graduates of non-AVMA/Council on Education (COE)-accredited veterinary colleges. The CPE is intended to assess the practical clinical veterinary skills of an "entry-level" veterinarian (ie, a new graduate of an AVMA/COE-accredited school). The CPE Manual of Administration lists the specific clinical proficiency skills measured by each section of the examination.

The ECFVG will provide reasonable accommodations designed to facilitate equal access to the CPE. Accommodations will be considered on a section-by-section basis. Because of the different clinical skills measured by the different sections, accommodations may be provided for some sections but not for others. In no case will accommodations be provided that would compromise any examination section's ability to test accurately the skills and knowledge it purports to measure. Similarly, no auxiliary aid or service will be provided that will fundamentally alter any section of the examination.

As part of the measurement of clinical "efficiency," candidates are assessed on their timely and effective use of resources to complete a procedure. Efficiency is a component of competency. Therefore, an accommodation of additional testing time will not be provided for those sections that assess efficiency. Similarly, no accommodations, including additional testing time, will be provided where the safety and welfare of an animal may be compromised.

While the use of accommodations in the test activity may enable the individual to better demonstrate his or her mastery of clinical skills, accommodations are not a guarantee of improved performance, test completion, or a passing score.

When to Request Test Accommodations for the CPE—Once the ECFVG office notifies a candidate who requires accommodations that he or she is eligible for the CPE, the candidate should request an ECFVG Test Accommodation Request Form for the Clinical Proficiency Examination (CPE) from the ECFVG office at the same time he or she requests a CPE application. A Test Accommodation Request form is also available in Appendix 8 of this Policies and Procedures Manual. The completed ECFVG Test Accommodation Request Form must be submitted to the ECFVG office at the same time as the completed CPE application. Appropriate documentation of the disabling condition and need for accommodations must accompany the ECFVG Test Accommodation Request Form. In order to facilitate processing, the ECFVG encourages applicants to provide detailed and complete responses to the request for test accommodations and accompanying documentation.

How to Request Test Accommodations for the CPE—If a candidate has a documented disability covered under the Americans with Disabilities Act (ADA) and requires test accommodations, he/she must notify the ECFVG in writing each time he/she applies for an accommodation. The individual requesting accommodations must personally initiate a written request for test accommodations. Accommodation requests by a third party (such as an evaluator or veterinary school) cannot be honored. Candidates should read and comply with the following seven steps to request accommodations:

  1. Read the General Guidelines for Documenting Disabilities, Guidelines for Documenting Learning Disabilities, and Guidelines for Documenting Attention-deficit/Hyperactivity Disorder and share them with the professional who will be preparing your documentation. Your treating professional must provide the necessary supporting documentation as described in these guidelines.
  2. Complete and sign the ECFVG Test Accommodation Request Form for the Clinical Proficiency Examination (CPE), which may be obtained by requesting a form in writing from the ECFVG office at the time you request a CPE application. Alternatively, if you are applying to retake one, two, or three failed sections of the CPE, complete and sign the ECFVG Request for Subsequent (Retake) Test Accommodations for the Clinical Proficiency Examination (CPE), which may also be obtained on written request from the ECFVG office.
  3. Attach documentation of the disability and your need for accommodation.
    1. Compare your documentation with the information listed in the General Guidelines for Documenting Disabilities, Guidelines for Documenting Learning Disabilities, and Guidelines for Documenting Attention-deficit/Hyperactivity Disorder to ensure a complete submission.
    2. Incomplete documentation will delay processing of your request.
  4. Attach a personal statement describing your disability and its impact on your ability to function in a clinical setting and in your daily life. If you are currently a practicing veterinarian, also describe any current workplace accommodations.
  5. Submit all documentation as outlined in the General Guidelines for Documenting Disabilities, Guidelines for Documenting Learning Disabilities, and Guidelines for Documenting Attention-deficit/Hyperactivity Disorder, including the following:
    1. Typed or printed letters and reports from evaluators on official letterhead.
    2. All documents in English. You are responsible for providing certified English translations of foreign-language documentation.
    3. Records from childhood if you are requesting accommodations based on a developmental disorder such as learning disorders (LD) or attention deficit/hyperactivity disorder (ADHD).
    4. Documentation of your functional impairment in activities beyond test-taking.
    5. Verification of your functional impairment by impartial third-party individuals who have observed you in day-to-day functioning or in clinical situations.
  6. Retain a photocopy of all Request Forms and documentation submitted.
  7. Send your completed ECFVG Test Accommodation Request Form for the CPE and documentation via a traceable or return-receipt method with your CPE application to:
       AVMA/ECFVG
       Attn: Testing Coordinator
       1931 N. Meacham Rd. Suite 100
       Schaumburg, IL 60173

General Guidelines for Documenting Disabilities—The following guidelines are provided to assist the applicant in documenting a need for accommodation based on an impairment that substantially limits one or more major life activities. To support a request for test accommodations, a candidate must please submit the following documentation from his/her testing professional:

  1. A detailed, comprehensive written report describing the candidate's disability and its severity and justifying the need for the requested accommodations. Documentation in support of requests for accommodations on the basis of a learning disability or attention-deficit/hyperactivity disorder must also comply with the Guidelines for Documenting Learning Disabilities or Guidelines for Documenting Attention-Deficit/Hyperactivity Disorder, respectively.
  2. The following characteristics are expected of all documentation submitted in support of a request for accommodations. Documentation must:
    1. State a specific diagnosis of the disability. A professionally recognized diagnosis for the particular category of disability is expected (eg, the DSM-IV diagnostic categories for learning disabilities).
    2. Be current. Because the provision of reasonable accommodations is based on assessment of the current impact of the examinee's disability on the testing activity, it is in the individual's best interest to provide recent documentation. As the manifestations of a disability may vary over time and in different settings, in most cases an evaluation should have been conducted within the past three years. For example, low vision or neuromuscular conditions are often subject to change and should be updated for current functioning.
    3. Describe the specific diagnostic criteria and name the diagnostic tests used, including date(s) of evaluation, specific test results, and a detailed interpretation of the test results. This description should include the results of diagnostic procedures and tests utilized and should include relevant educational, developmental, and medical history. Specific test results should be reported to support the diagnosis. For example, documentation for an examinee with multiple sclerosis should include specific findings on the neurological examination including functional limitations and MRI or other studies, if relevant. Diagnostic methods used should be appropriate to the disability and current professional practices within the field. Informal or non-standardized evaluations should be described in enough detail that other professionals could understand their role and significance in the diagnostic process.
    4. Describe in detail the individual's limitations due to the diagnosed disability (ie, a demonstrated impact on functioning on the CPE) and explain the relationship of the test results to the identified limitations resulting from the disability. The current functional impact on physical, perceptual, and cognitive abilities should be fully described (eg, the extent to which an examinee with macular degeneration and resulting reduced central vision is limited in the ability to read).
    5. Recommend specific accommodations and/or assistive devices including a detailed explanation of why these accommodations or devices are needed and how they will reduce the impact of the identified functional limitations. Accommodation requests for the CPE and their justification must be section specific. For example, a request for special lighting might be appropriate for the Surgery section, but not for the Small Animal Practice section. Extra time might be appropriate for the written stations in such sections as Small Animal Practice and Radiology but not for sections requiring demonstration of competencies required in Anesthesia or Surgery.
    6. Establish the professional credentials of the evaluator that qualify him or her to make the particular diagnosis, including information about licensure or certification and specialization in the area of the diagnosis. The evaluator should present evidence of comprehensive training and direct experience in the diagnosis and treatment of adults in the specific area of disability.
  3. If no prior accommodations have been provided, the qualified professional expert should include a detailed explanation as to why no accommodations were given in the past and why accommodations are needed now.

Guidelines for Documenting Learning Disabilities—The following information is provided to clarify the documentation process for applicants submitting a request for accommodations based specifically on a learning disability or cognitive impairment.

  1. The evaluation must be conducted by a qualified professional. The qualified professional (diagnostician) must have comprehensive training in the field of learning disabilities and must have comprehensive training and direct experience in working with an adult population.
  2. Testing/assessment must be current. The determination of whether an individual is significantly limited in functioning according to ADA criteria is based on assessment of the current impact of the impairment. (See General Guidelines for Documenting Disabilities). A developmental disorder such as a learning disability originates in childhood and, therefore, information which demonstrates a history of impaired functioning should also be provided.
  3. Documentation must be comprehensive. Objective evidence of a substantial limitation in cognition or learning must be provided. At a minimum, the comprehensive evaluation should include the following:
    1. A diagnostic interview and history taking. Because learning disabilities are commonly manifested during childhood, though not always formally diagnosed, relevant historical information regarding the individual's academic history and learning processes in elementary, secondary and postsecondary education should be investigated and documented. The report of assessment should include a summary of a comprehensive diagnostic interview that includes relevant background information to support the diagnosis. In addition to the candidate's self-report, the report of assessment should include:
      • A description of the presenting problem(s);
      • A developmental history;
      • Relevant academic history including results of prior standardized testing, reports of classroom performance and behaviors including transcripts, study habits and attitudes and notable trends in academic performance;
      • Relevant family history, including primary language of the home and current level of fluency in English;
      • Relevant psychosocial history;
      • Relevant medical history including the absence of a medical basis for the present symptoms;
      • Relevant employment history;
      • A discussion of dual diagnosis, alternative or co-existing mood, behavioral, neurological and/or personality disorders along with any history of relevant medication and current use that may impact the individual's learning; and
      • sExploration of possible alternatives that may mimic a learning disability when, in fact, one is not present.
    2. A psychoeducational or neuropsychological evaluation. The psychoeducational or neuropsychological evaluation must be submitted on the letterhead of a qualified professional, and it must provide clear and specific evidence that a learning or cognitive disability does or does not exist. It must also have the following characteristics:
      • The assessment must consist of a comprehensive battery of tests.
      • A diagnosis must be based on the aggregate of test results, history and level of current functioning. It is not acceptable to base a diagnosis on only one or two subtests.
      • Objective evidence of a substantial limitation to learning must be presented.
      • Tests must be appropriately normed for the age of the patient and must be administered in the designated standardized manner.
      • Minimally, the domains to be addressed in the psychoeducational or neuropsychological evaluation should include assessment of:
        1. Cognitive Functioning: A complete cognitive assessment is essential with all subtests and standard scores reported. Acceptable measures include but are not limited to: Wechsler Adult Intelligence Scale-III (WAIS-III); Woodcock Johnson Psychoeducational Battery-III (WJ-III): Tests of Cognitive Ability; Kaufman Adolescent and Adult Intelligence Test.
        2. Achievement: A comprehensive achievement battery with all subtests and standard scores is essential. The battery must include current levels of academic functioning in relevant areas such as reading (decoding and comprehension) and mathematics. Acceptable instruments include, but are not limited to, the Woodcock-Johnson Psychoeducational Battery - Revised: Tests of Achievement (WJ-III); The Scholastic Abilities Test for Adults (SATA); Woodcock Reading Mastery Tests-III. Specific achievement tests are useful instruments when administered under standardized conditions and when interpreted within the context of other diagnostic information. The Wide Range Achievement Test-3 (WRAT-3) and the Nelson-Denny Reading Test are not comprehensive diagnostic measures of achievement and therefore neither is acceptable if used as the sole measure of achievement.
        3. Information Processing: Specific areas of information processing (e.g., short- and long-term memory, sequential memory, auditory and visual perception/processing, auditory and phonological awareness, processing speed, executive functioning, motor ability) must be assessed. Acceptable measures include, but are not limited to, the Detroit Tests of Learning Aptitude - Adult (DTLA-A), Wechsler Memory Scale-III (WMS-III), information from the Woodcock Johnson Psychoeducational Battery-III Tests of Cognitive Ability, as well as other relevant instruments that may be used to address these areas.
        4. Other Assessment Measures: Other formal assessment measures or nonstandard measures and informal assessment procedures or observations may be integrated with the above instruments to help support a differential diagnosis or to disentangle the learning disability from co-existing neurological and/or psychiatric issues. In addition to standardized test batteries, nonstandardized measures and informal assessment procedures may be helpful in determining performance across a variety of domains.
  4. Actual test scores must be provided (age-based standard scores where available) as well as identification of norms used to interpret the data. Evaluators should use the most recent form of tests and should identify the specific test form as well as the norms used to compute scores. It is helpful to list all test data in a score summary sheet appended to the evaluation.
  5. Records of academic history should be provided. Because learning disabilities are most commonly manifested during childhood, relevant records detailing learning processes and difficulties in elementary, secondary and postsecondary education should be included. Such records as grade reports, transcripts, teachers' comments and the like will serve to substantiate self-reported academic difficulties in the past and present.
  6. A differential diagnosis must be reviewed and various possible alternative causes for the identified problems in academic achievement should be ruled out. The evaluation should address key constructs underlying the concept of learning disabilities and provide clear and specific evidence of the information processing deficit(s) and how these deficits currently impair the individual's ability to learn. No single test or subtest is a sufficient basis for a diagnosis. The differential diagnosis must demonstrate that:
    1. Significant difficulties persist in the acquisition and use of listening, speaking, reading, writing or reasoning skills.
    2. The problems being experienced are not primarily due to lack of exposure to the behaviors needed for academic learning or to an inadequate match between the individual's ability and the instructional demands.
  7. A clinical summary must be provided. A well-written diagnostic summary based on a comprehensive evaluative process is a necessary component of the report. Assessment instruments and the data they provide do not diagnose; rather, they provide important data that must be integrated with background information, historical information and current functioning. It is essential then that the evaluator integrates all information gathered in a well-developed clinical summary. The following elements must be included in the clinical summary:
    1. Demonstration of the evaluators having ruled out alternative explanations for the identified academic problems as a result of poor education, poor motivation and/or study skills, emotional problems, attentional problems and cultural or language differences;
    2. Indication of how patterns in cognitive ability, achievement and information processing are used to determine the presence of a learning disability;
    3. Indication of the substantial limitation to learning presented by the learning disability and the degree to which it impacts the individual in the context of the CPE; and
    4. Indication as to why specific accommodations are needed and how the effects of the specific disability are mediated by the recommended accommodation(s).
  8. Each accommodation recommended by the evaluator must include a rationale. The evaluator must describe the impact the diagnosed learning disability has on a specific major life activity as well as the degree of significance of this impact on the individual. The diagnostic report must include specific recommendations for accommodations and a detailed explanation as to why each accommodation is recommended. Recommendations must be tied to specific diagnostic test results or clinical observations. The documentation should include any record of prior accommodation or auxiliary aids, including any information about specific conditions under which the accommodations were used and whether or not they were effective. However, a prior history of accommodation, without demonstration of a current need, does not in and of itself warrant the provision of a like accommodation. If no prior accommodation(s) has been provided, the qualified professional expert should include a detailed explanation as to why no accommodation(s) was used in the past and why accommodation(s) is needed at this time.
  9. Problems such as test anxiety, English as a second language in and of itself, slow reading without an identified underlying cognitive deficit or failure to achieve a desired academic outcome are not learning disabilities and, therefore, are not covered under the ADA.

Guidelines for Documenting Attention-Deficit/Hyperactivity Disorder (ADHD)—For those applicants submitting a request for accommodations based specifically on Attention-Deficit/Hyperactivity Disorder (ADHD), the following additional information is provided to clarify the documentation process:

  1. The evaluation must be conducted by a qualified diagnostician. Professionals conducting assessments and rendering diagnoses of ADHD must be qualified to do so. Comprehensive training in the differential diagnosis of ADHD and other psychiatric disorders and direct experience in diagnosis and treatment of adults is necessary. The evaluator's name, title and professional credentials, including information about license or certification as well as the area of specialization, employment and state in which the individual practices should be clearly stated in the documentation.
  2. Testing/assessment must be current. The determination of whether an individual is "significantly limited" in functioning is based on assessment of the current impact of the impairment on the CPE (see General Guidelines for Documenting Disabilities).
  3. Documentation necessary to substantiate the ADHD must be comprehensive. Because ADHD is, by definition, first exhibited in childhood (although it may not have been formally diagnosed) and in more than one setting, objective, relevant, historical information is essential. Information verifying a chronic course of ADHD symptoms from childhood through adolescence to adulthood, such as educational transcripts, report cards, teacher comments, tutoring evaluations, job assessments, and the like are necessary.
    1. The evaluator is expected to review and discuss DSM-IV diagnostic criteria for ADHD and describe the extent to which the patient meets these criteria. The report must include information about the specific symptoms exhibited and document that the patient meets criteria for long-standing history, impairment, and pervasiveness.
    2. A history of the individual's presenting symptoms must be provided, including evidence of ongoing impulsive/hyperactive or inattentive behaviors (as specified in DSM-IV) that significantly impair functioning in two or more settings.
    3. The information collected by the evaluator must consist of more than a self-report. Information from third party sources is critical in the diagnosis of adult ADHD. Information gathered in the diagnostic interview and reported in the evaluation should include, but not necessarily be limited to, the following:
      • History of presenting attentional symptoms, including evidence of ongoing impulsive/hyperactive or inattentive behavior that has significantly impaired functioning over time;
      • Developmental history;
      • Family history for presence of ADHD and other educational, learning, physical, or psychological difficulties deemed relevant by the examiner;
      • Relevant medical and medication history, including the absence of a medical basis for the symptoms being evaluated;
      • Relevant psychosocial history and any relevant interventions;
      • A thorough academic history of elementary, secondary, and postsecondary education;
      • Review of psychoeducational test reports to determine if a pattern of strengths or weaknesses is supportive of attention or learning problems;
      • Evidence of impairment in several life settings (home, school, work, etc) and evidence that the disorder significantly restricts one or more major life activities.
      • Relevant employment history;
      • Description of current functional limitations relative to a clinical practice setting and to the CPE in particular that are presumably a direct result of the described problems with attention;
      • A discussion of the differential diagnosis, including alternative or co-existing mood, behavioral, neurological, or personality disorders that may confound the diagnosis of ADHD; and
      • Exploration of possible alternative diagnoses that may mimic ADHD.
  4. Relevant assessment batteries must be described. A neuropsychological or psychoeducational assessment may be necessary in order to determine the individual's pattern of strengths or weaknesses and to determine whether there are patterns supportive of attention problems. Test scores or subtest scores alone should not be used as the sole basis for the diagnostic decision. Scores from subtests on the Wechsler Adult Intelligence Scale - III (WAIS - III), measures of memory function, or attention or tracking tests or continuous performance tests do not in and of themselves establish the presence or absence of ADHD. They may, however, be useful as one part of the process in developing clinical hypotheses. Checklists or surveys can serve to supplement the diagnostic profile but by themselves are not adequate for the diagnosis of ADHD. When testing is used, age-based standard scores must be provided for all normed measures.
  5. Identification of DSM-IV criteria. A diagnostic report must include a review of the DSM-IV criteria for ADHD both currently and retrospectively and specify which symptoms are present (see DSM-IV for specific criteria). According to DSM-IV, "the essential feature of ADHD is a persistent pattern of inattention and/or hyperactivity-impulsivity that is more frequent and severe than is typically observed in individuals at a comparable level of development." Other criteria include:
    1. Symptoms of hyperactivity-impulsivity or inattention that cause impairment that were present in childhood.
    2. Current symptoms that have been present for at least the past six months.
    3. Impairment from the symptoms present in two or more settings (school, work, home, etc).
  6. Documentation must include a specific diagnosis. The report must include a specific diagnosis of ADHD based on the DSM-IV diagnostic criteria. Individuals who report problems with organization, test anxiety, memory, and concentration only on a situational basis do not fit the prescribed diagnostic criteria for ADHD. Given that many individuals benefit from prescribed medications and therapies, a positive response to medication by itself is not supportive of a diagnosis, nor does the use of medication in and of itself either support or negate the need for accommodation.
  7. A clinical summary must be provided. A well-written diagnostic summary based on a comprehensive evaluative process is a necessary component of the assessment. The clinical summary must include:
    1. Demonstration of the evaluators having ruled out alternative explanations for inattentiveness, impulsivity, and/or hyperactivity as a result of psychological or medical disorders or non-cognitive factors;
    2. Indication of how patterns of inattentiveness, impulsivity, and/or hyperactivity across the life span and across settings are used to determine the presence of ADHD;
    3. Indication of the substantial limitation to learning presented by ADHD and the degree to which it impacts the individual in the context for which accommodations are being requested (eg, impact on the CPE); and
    4. Indication as to why specific accommodations are needed for the CPE and how the effects of ADHD symptoms, as designated by the DSM-IV, are mediated by the accommodation(s).
  8. Each accommodation recommended by the evaluator must include a rationale. The evaluator must describe the impact of ADHD (if one exists) on a specific major life activity as well as the degree of significance of this impact on the individual. The diagnostic report must include specific recommendations for accommodations. A detailed explanation must be provided as to why each accommodation is recommended and should be correlated with specific identified functional limitations. Prior documentation may have been useful in determining appropriate services in the past. However, documentation should validate the need for accommodation based on the individual's current level of functioning. The documentation should include any record of prior accommodation or auxiliary aid, including information about specific conditions under which the accommodation was used (eg, standardized testing, final exams, etc). However, a prior history of accommodation without demonstration of a current need does not in itself warrant the provision of a similar accommodation. If no prior accommodation has been provided, the qualified professional and/or individual being evaluated should include a detailed explanation as to why no accommodation was used in the past and why accommodation is needed at this time.
  9. Because of the challenge of distinguishing ADHD from normal developmental patterns and behaviors of adults, including procrastination, disorganization, distractibility, restlessness, boredom, academic underachievement or failure, low self-esteem, and chronic tardiness or inattendance, a multifaceted evaluation must address the intensity and frequency of the symptoms and whether these behaviors constitute impairment in a major life activity.

Confidentiality—Except where necessary to make a determination of appropriate accommodations, the ECFVG does not disclose names of applicants with disabilities or information concerning the application or accompanying documentation. In that event, such information shall be disclosed only to outside experts and other consultants. Entities receiving verification of certification are not advised of any accommodations provided to the subject candidate.